Split 3rd Circuit Panel: Recess Appointment To Labor Board Was Invalidhttp://www.lexisnexis.com/legalnewsroom/mealeys/b/newsheadlines/archive/2013/05/17/split-3rd-circuit-panel-recess-appointment-to-labor-board-was-invalid.aspxPHILADELPHIA - President Obama&#39;s appointment of a member to the National Labor Relations Board in 2010 during a break in a session of the U.S. Senate was invalid, a split Third Circuit U.S. Court of Appeals panel ruled May 16 (National Labor Relationsen-US6.x Production